Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Petroleum-operation equipment moved from the DTA to an FTWZ after completion of its original contract and then returned to the DTA under a fresh essentiality certificate does not qualify for the residuary re-import exemption under Serial No. 5 of Notification No. 45/2017-Customs. The conditional petroleum-operation concession under Notification No. 50/2017-Customs is limited to certified use for the specified operation and includes its own transfer mechanism for eligible operations; an FTWZ movement cannot create an additional fiscal benefit. The SEZ statutory fiction is limited in scope, and equipment identity alone does not establish continuity with the original outward movement. FTWZ-to-DTA clearance for a new domestic contract is a fresh import, making the re-import exemption unavailable.
Petroleum-operation equipment moved from the DTA to an FTWZ after completion of its original contract and then returned to the DTA under a fresh essentiality certificate does not qualify for the residuary re-import exemption under Serial No. 5 of Notification No. 45/2017-Customs. The conditional petroleum-operation concession under Notification No. 50/2017-Customs is limited to certified use for the specified operation and includes its own transfer mechanism for eligible operations; an FTWZ movement cannot create an additional fiscal benefit. The SEZ statutory fiction is limited in scope, and equipment identity alone does not establish continuity with the original outward movement. FTWZ-to-DTA clearance for a new domestic contract is a fresh import, making the re-import exemption unavailable.
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